Apart from the general principles of respecting the law, transparency, honesty, propriety and good faith, the Code of Ethics highlighted the importance of sustainable development, including the company's responsibility to the countries where it operates, safeguarding the rights of third generations and defending and promoting Human Rights.

The general principles are set out in different ways according to the various types of stakeholders, with particular emphasis placed on:
- relations with shareholders and the market: Eni's commitment to creating value for its shareholders must be carried out in compliance with the principles of market propriety, which  include adhering to the main regulations concerning corporate governance, company information and relations with the media, which are based on transparency, propriety and also opportuneness and accuracy;
- relations with institutions and local communities: the Code introduced the obligation for active cooperation with public institutions and reiterated the company's commitment to developing local communities by, among other things, providing information, reaching agreement on subjects that interest them the most and supporting non-profit activities;
- relations with clients and consumers. The Code expressly includes the right to not receive products that damage the health and to receive complete information on the products on offer.

Particular attention is obviously given to relations with Eni personnel. Emphasis is placed on developing and protecting people and their diversities, in order to ensure that there is always a climate of reciprocal respect and collaboration in the workplace.

This area also includes the new subjects of company security and knowledge management.
All regulations referring to acceptable practice are guaranteed by specific instruments such as  internal control systems, the responsibility to avoid and, in any case, signal any situations involving a conflict of interest, the safeguarding of health, security, the environment and public safety, the promotion of research and innovation and the safeguarding of intellectual property.
With regard to internal control, the role of Guarantor of the Code of Ethics is entrusted to a Control and Vigilance Body in accordance with Model 231, in order to create synergy and increased efficiency among the various control bodies.

The last fundamental innovation concerns the introduction of a Code of Ethics Promotion Team, created in order to ensure that the Code is promoted as much as possible both inside and outside Eni, in the knowledge that this instrument must be understood and internalised by everyone if it is to be essential and functional.

Sharing and training are essential in order to ensure that Eni’s Code of Ethics is a part of the assets of everyone who works at the company. To this end a team has been put together, reporting directly to the Guarantor of the Code of Ethics, to promote and spread the content of the Code and gather from all interested parties ideas and suggestions for its continuous improvement.

To ensure the maximum exposure in the international context in which Eni operates, the Code of Ethics has been translated into German, French, Portuguese, Spanish, Russian, Hungarian, Romanian, Polish, Arabic, Greek, Dutch, Slovak, Slovenian, Turkish, Czech, Bahasa Indonesian, Flemish and Kazakh, as well as Italian and English.

A process for general distribution has been organised, supported by internal communication activities and a training plan able to reach all levels within the company from the Board of Directors to recently hire graduates, through differentiated actions that make use also of interactive tools as well as presentations aimed at integrating the company’s institutional training courses.

A web seminar on the Code of Ethics was organised in 2009 that involved more than 3,000 executives, managers and Key Officers from eni’s subsidiary companies. The seminar - available also with subtitles in English - is now accessible by all Eni employees through a dedicated web page on the company’s intranet.

The team set up to promote the Code of Ethics has also launched a consultation process with stakeholders. In addition to Eni people, involved in specially constituted focus groups and online forums, questionnaires and dedicated discussion groups have been used to gather feedback from institutional and socially responsible investors, the leading trade union organisations, the principal rating agencies, consumers’ associations, as well as a representative sample of suppliers, sales people and franchisees. The Code of Ethics was presented at the Cassa Depositi e Prestiti and at the Treasury Department of the Italian Ministry of the Economy.
Finally, Eni has requested critical comments on its Code of Ethics from a range of non-governmental organisations, including environmentalist groups and others committed to the protection of human rights and organisations engaged in the study and research of corporate ethics and the management of socially responsible investments.

Evaluations of the Code of Ethics - which are immediately forwarded to the Guarantor of the Code of Ethics who, in turn, regularly reports to the company’s top management - were, overall, positive. The document has been judged complete and clear and, to date, no proposals for modifications have been received.
In 2009 eni was judged, in the context of the "Dow Jones Sustainability Index World", "Best in class" for the area concerning "Code of Practice / Compliance".

There are clear synergies between the Code of Ethics and the Model 231, of which the Code is an integral part and general principle. This can be seen from the attribution to Eni’s Body of Control 231 of the function of Guarantor of the Code of Ethics.

Given the complexity of Eni’s organisational structure and the application across the company of the Model 231, the update of Model 231 - approved by the Board of Directors on 14 March 2008 - involved the implementation of a programme of adherence to innovations, identified and created by a specially constituted multi-functional team ("Team 231"), that includes the Chief Executive and contributions from competent functions within the company.

During 2009, Team 231 oversaw the changes to Model 231 with regard to illegal acts including the receipt, recycling or use of money, goods or other assets from illicit sources, and cyber crime or the misuse of data, and, in the short term, will include a series of crimes introduced in 2009 by the Italian parliament, including those that are subject to the sanctions foreseen by the Legislative Decree n. 231 of 2001 (organised crime, crimes against industry and trade, copyright and intellectual property violations, as well as failure to cooperate with judicial authorities or attempts to deviate the course of justice).

Finally, in 2009 a web-based training initiative was introduced covering the principles contained in the Legislative Decree n. 231 of 2001  and Model 231.

In 2010 training will be introduced and completed specifically aimed at Eni executives and managers.